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What are examples of undergraduate professional programs that do not meet the Dept. of Education's professional degree definition?
Executive summary
The Department of Education’s negotiated-rulemaking discussions and a draft proposal would narrow the federal definition of “professional degree” in ways that—according to reporting and professional groups—would exclude many programs long treated as professional, including most graduate nursing tracks, audiology, speech‑language pathology, physician assistant, occupational therapy, public health, and social work programs [1] [2] [3]. Reporting and advocacy groups warn this could shrink the number of programs classed as professional from roughly 2,000 to under 600 and reduce students’ access to higher loan limits tied to that status [4] [5].
1. What the Department of Education’s proposal would change
A Department of Education draft definition discussed at RISE/negotiated‑rulemaking would add specific criteria—such as multi‑year/doctoral‑level duration, alignment with professional licensure and placement in selected Classification of Instructional Programs (CIP) codes—that many current graduate‑level health and human‑service programs do not meet; negotiators say this technical framing would exclude programs like advanced nursing and many allied‑health degrees from the “professional” label [1] [6].
2. Examples of programs likely to lose “professional” status under the draft
Multiple outlets and associations identify specific programs at risk: graduate nursing tracks (MSN, DNP), physician assistant programs, occupational therapy, physical therapy, audiology, speech‑language pathology, public health (MPH, DrPH), social work (MSW, DSW), and some counseling degrees are named in reporting as not meeting the proposed definition [7] [1] [2] [3].
3. How this reclassification affects student loans and borrowing caps
Under the One Big Beautiful Bill Act (OBBBA) framework the draft implements, only programs designated “professional” would be eligible for the higher loan caps (for example, historically higher annual borrowing available to professional students); narrowing the list would mean many students in the excluded programs would face lower annual loan limits or lose access to Grad PLUS‑style borrowing, with estimates of annual caps dropping from about $50,000 to roughly $20,000 for affected graduate students [1] [8].
4. Who’s sounding the alarm — and why
National associations for affected fields (nursing, public health, audiology, speech‑language pathology) and major higher‑education groups like the Association of American Universities argue the change would “threaten access to advanced training,” shrink pipelines for faculty and clinicians, and undermine workforce capacity in critical health sectors [1] [5] [2] [3]. Their concerns focus on practical consequences for enrollment, patient care and public‑health readiness [1] [9].
5. Procedural context: negotiated rulemaking and contested criteria
The definition is emerging from a Department‑convened negotiated rulemaking (the RISE committee) to implement OBBBA loan provisions; negotiators debated criteria such as required credit hours, CIP code grouping, and whether a program must be “generally at the doctoral level” or meet multi‑year/credit thresholds. Some committee members and representatives of institutions and taxpayers expressed unease about vagueness and legal risk, noting the proposal’s potential to affect undergraduate program definitions as well [6].
6. Disagreements, ambiguity, and what’s not yet settled
There is not a single, finalized federal list published in the materials cited; insiders report a “consensus draft” but committee members differ on specifics and support is uneven. The department’s own summaries show a potential universe of about 44 CIP codes that could qualify, but actual qualifying programs would be fewer once all criteria are applied—this indicates substantial uncertainty about which exact programs ultimately qualify or don’t [6] [4].
7. How groups and reporters are responding—two perspectives
Advocates for affected professions frame the change as a blunt instrument that cuts funding access and endangers workforce capacity [1] [3]. The department and some negotiators argue the tighter definition is intended to clarify eligibility and limit a sprawling set of programs that previously qualified—an effort framed as aligning loan policy with program structure and licensure—but critics say the draft’s technical requirements will unintentionally exclude legitimate professional pathways [6] [5].
8. What to watch next and how stakeholders can respond
The rulemaking process continues: further committee meetings, public comment windows, and congressional engagement are expected; professional groups have mobilized advocacy and congressional outreach to press for inclusion of their fields [2] [5]. Readers should expect formal federal notices, opportunities for public comment, and potential litigation if stakeholders believe the definition is legally flawed [6].
Limitations: available sources discuss the draft proposal, reporting, and reactions but do not provide an official finalized federal list of programs that will definitively lose “professional” status; claims about exact program counts and final loan amounts are based on draft proposals and advocacy estimates rather than a completed rule [6] [4].